https://www.taxtmi.com/caselaws?id=460285 Expatriate employees seconded to an Indian subsidiary did not create a fixed place permanent establishment under Article 5 of the India-Korea DTAA because their activities were confined to the subsidiary's operations, coordination, and reporting, with no proof that the assessee's own core business decisions were carried on in India. The estimated attribution based on 10% of the seconded employees' remuneration cost therefore lacked any surviving basis and was deleted. The claim for tax deducted at source credit was not decided finally and was remanded to the Assessing Officer for verification and consequential grant in accordance with law. en-us Mon, 22 Mar 2021 00:00:00 +0530 Fri, 17 Jan 2025 20:05:54 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=460285 Expatriate employees seconded to an Indian subsidiary did not create a fixed place permanent establishment under Article 5 of the India-Korea DTAA because their activities were confined to the subsidiary's operations, coordination, and reporting, with no proof that the assessee's own core business decisions were carried on in India. The estimated attribution based on 10% of the seconded employees' remuneration cost therefore lacked any surviving basis and was deleted. The claim for tax deducted at source credit was not decided finally and was remanded to the Assessing Officer for verification and consequential grant in accordance with law. Case-Laws Income Tax Mon, 22 Mar 2021 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=460285